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The High Court of Madras ruled in favor of the assessee, determining that the consideration received for the sale of business was for goodwill and not a license fee. The transfer of goodwill to the limited companies did not negate the personal right of the assessee to continue using the business name. The amount of Rs. 20,000 was not taxable as goodwill was not taxable under the law at that time. The judgment was against the Revenue and in favor of the assessee.
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